Michele Perrin v Jackie Walsh

Michele Perrin v Jackie Walsh

The surveillance evidence, despite procedural flaws and negligent editing, was not deliberately manipulated to prejudice the Claimant and retains probative value. The errors do not reach the threshold for exclusion under CPR 32.1. All unedited footage must be disclosed, and a new compilation agreed. The Claimant is not entitled to inspection of the Defendant's neuropsychologist's draft report, as privilege was not waived and CPR 35.10(3) was complied with; no reasonable grounds exist to consider the statement of instructions inaccurate or incomplete.

Parties
Claimant: Mrs Michele Perrin; Defendant: Ms Jackie Walsh
Jurisdiction
England and Wales
Judgment Date
10 September 2025
Procedural Posture
Personal Injury / Interlocutory Judgment on Evidentiary and Disclosure Applications
Outcome
Defendant permitted to rely on surveillance evidence; Claimant's application for disclosure of draft expert report refused.
Legal Topics
Surveillance Evidence, Disclosure of Expert Reports, Litigation Privilege, Case Management, Fundamental Dishonesty
Civil Procedure Personal Injury Surveillance Evidence Disclosure of Expert Reports Litigation Privilege Case Management Fundamental Dishonesty

Case Brief

Summary, issues, holding and outcome

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Parties

Mrs Michele Perrin

Claimant

Ms Jackie Walsh

Defendant

Procedural Posture

Personal Injury / Interlocutory Judgment on Evidentiary and Disclosure Applications

Legal Issues

  1. 1 Whether surveillance evidence obtained by the Defendant should be excluded due to alleged manipulation and procedural flaws
  2. 2 Whether the Claimant is entitled to specific disclosure and inspection of the Defendant's neuropsychologist's draft report

Ratio Decidendi

The surveillance evidence, despite procedural flaws and negligent editing, was not deliberately manipulated to prejudice the Claimant and retains probative value. The errors do not reach the threshold for exclusion under CPR 32.1. All unedited footage must be disclosed, and a new compilation agreed. The Claimant is not entitled to inspection of the Defendant's neuropsychologist's draft report, as privilege was not waived and CPR 35.10(3) was complied with; no reasonable grounds exist to consider the statement of instructions inaccurate or incomplete.

Court Disposition

Defendant permitted to rely on surveillance evidence; Claimant's application for disclosure of draft expert report refused.

Orders

  • All unedited surveillance footage to be served on the Claimant within seven days.
  • Parties to agree a new compilation of edited surveillance footage; failing agreement, further hearing to determine.